Missing from fish consumption debate: what fish Washingtonians actually eat

The state’s most unimportant-sounding vital statistic is back in the news: the fish consumption rate. Remember this issue?

It may sound like a matter more suited to grad students in the nutritional science department, but the fish consumption rate (FCR) matters because the more fish Washingtonians eat, the more stringent water quality standards are required to be.

Many have been concerned that extremely high standards would drive businesses out of the state by driving up costs and requiring, in some cases, that discharged water be even cleaner than the river or other source it was taken from.

Cities, too, worry they could need to invest vast sums in new water treatment technologies, but still not meet the standards. One study estimated that needed upgrades in Bellingham could lead to $200-250 a month sewer rates. That would be an absurd conclusion.

Gov. Inslee and his Dept. of Ecology outlined a few weeks ago where they intend to lead the FCR process. Ecology will raise the FCR significantly, from 6.5 grams a day, which is about one fish meal per month, to 175 grams a day, or about one fish meal per day. That is the same rate as Oregon set two years ago.

To the chagrin of some environmentalists, they are also raising the acceptable rate of cancer from fish consumption. The governor says he will deal with the overall health of Washington waters by introducing a toxics reduction bill in the Legislature next year.

Give Inslee and Ecology some credit; they are trying to strike a balance. They seem to recognize there are real-world consequences to setting standards so high that they’re unachievable. It is still much too early to know what the actual costs will be, though. It’s too early to tell even in Oregon, which is two years ahead of us in this same process.

One thing has bothered me throughout this debate, though. A matter like this should be driven by science, but the most important number determining these standards – the fish consumption rate – isn’t scientific at all.

How’s that, you ask? I’m not referring to the fact that the 175 grams per day FCR is somewhat arbitrary, though that is true. No, what I mean is that no one has conducted a comprehensive study on how much of the fish consumed by Washingtonians is from local waters. The debate has swirled, but the need for an overall picture of our state’s fish consumption has been ignored.

Take, for instance, someone who eats 175 grams of fish per day, but their tastes ran toward Alaskan halibut, Copper River salmon, canned tuna and sardines, and pickled herring. For such a consumer, Washington’s water standards would mean next to nothing for the safety of their fish diet. Potentially drastic consequences will follow the final FCR determination, despite basic facts about Washingtonians actual fish consumption remaining unexplored.

There seems to be a bit of willful blindness behind this missing piece of the puzzle. Perhaps before the state goes further into this process, it should acquire some actual data about not just the amount of fish Washingtonians eat, but the sources of those fish. That would be a scientific approach.
-Rob McKenna

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Rob McKenna
Rob served two terms as Washington’s Attorney General, from 2005 to 2013. He successfully argued three cases before the U.S. Supreme Court and negotiated three of the largest consumer financial protection settlements in national history, all involving mortgage lending and servicing. He is a recognized leader in the development of consumer protections on the internet, in data protection and privacy regulation.
  • Audrey9992

    Interesting point. I agree it seems a key statistic is missing. Perhaps, when weighing the option they thought best to make an assumption rather than spend money and time for a difficult study to be conducted. A bit of a roll of the dice with that one. It seems like a safe assumption, but the cost long term if the assumption was wrong can bite us in the end. Only time will truly tell. In the same respect I am not quite willing to get all persnickety over fish even if I do think 175 grams is grossly inaccurate.

  • Keith Badgley

    That is why you don’t make assumptions, they can be grossly inaccurate and lead to unintended consequences. It is always better to look at the unbiased science, as well as we can, before embarking on something like this. Fish consumed a day is only a guess, and it may not closely correlate with Washington fish consumed per day. Two strikes. The third strike will come whe Inslee implements this and causes and even greater burden on citizens.